HHS Special Exposure Cohort Determination:

General Steel Industries, Granite City, Illinois

HHS Determination Concerning a Petition to Add Members to the 

Special Exposure Cohort

under the 

Energy Employees Occupational Illness Compensation Program Act of 2000

Determination Concerning a Petition for Employees from 

General Steel Industries

Granite city, Illinois
HHS Special Exposure Cohort Determination:

General Steel Industries, Granite City, Illinois

Page 1

I. Determination

I, Kathleen Sebelius, Secretary of the Department of Health and Human Services (HSS), have 

determined that the employees defined in Section II of this report do not meet the statutory criteria for 

addition to the Special Exposure Cohort (SEC), as authorized under the Energy Employees 

Occupational Illness Compensation Program Act of 2000 (EEOICPA), 42 U.S.C. § 7384q.

[Signature on File] March 6, 2013

_________________________ _______________________

Kathleen Sebelius Date

II. Employee Class Definition

All individuals who worked in any location at the General Steel Industries site, located at 

1417 State Street, Granite City, Illinois, from January 1, 1953, through June 30, 1966, and/or 

during the residual radiation period from July 1, 1966, through December 31, 1992.

III. Decision Criteria and Recommendations

Pursuant to 42 U.S.C. § 7384q, to designate a class for addition to the SEC, the Secretary must 

determine, upon recommendation of the Advisory Board on Radiation and Worker Health (Board), 

that

(1) it is not feasible to estimate with sufficient accuracy the radiation dose that the class received; 

and

(2) there is a reasonable likelihood that such radiation dose may have endangered the health of 

members of the class.

The SEC final rule states in 42 C.F.R. § 83.13(c)(1) that it is feasible in two situations to estimate the 

radiation dose that the class received with sufficient accuracy. First, the rule states that radiation 

doses may be estimated with sufficient accuracy if NIOSH has established that it has access to 

sufficient information to estimate the maximum radiation dose for every type of cancer for which 

radiation doses are reconstructed that could have been incurred under plausible circumstances by any 

member of the class. Alternatively, radiation doses may be estimated with sufficient accuracy if 

NIOSH has established that it has access to sufficient information to estimate the radiation doses of 

members of the class more precisely than a maximum dose estimate. NIOSH determined that it has 

access to sufficient information to reconstruct radiation doses incurred by the class of employees 

covered by this report with sufficient accuracy. 

In a letter received by the Secretary on February 4, 2013, the Board, pursuant to 42 U.S.C. § 7384q,

agreed with the following NIOSH findings, effectively advising the Secretary that radiation dose can 

be reconstructed with sufficient accuracy for certain General Steel Industries (GSI), Granite City, 

Illinois, employees in accordance with provisions of EEOICPA and the SEC final rule.
HHS Special Exposure Cohort Determination:

General Steel Industries, Granite City, Illinois

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IV. Determination Findings

Feasibility of Estimating Radiation Doses with Sufficient Accuracy

The Secretary established the feasibility determination for the class of employees covered by this 

report based upon the findings summarized below.

• The principal sources of internal radiation doses for members of the proposed class include 

inhalation and ingestion of uranium dust from handling uranium metal, fission and activation 

products from handling and examining the uranium following x-ray operations, and 

activation products from steel castings handled and examined following x-ray operations

• NIOSH evaluated the potential exposures from possible intakes of radioactive material at GSI 

based on air-monitoring data from other facilities for the operational period. Internal 

exposures from the residual period were estimated by modeling the resuspension of surface 

contamination levels to determine airborne levels that would bound intakes for GSI. 

• A principal source of external radiation doses for members of the proposed class was from 

activities associated with the betatron machines. Based on workers’ film badge doses and 

modeled exposures using Monte Carlo techniques, NIOSH has determined that is possible to 

plausibly bound external doses associated with the evaluation of uranium and steel using the 

betatron.

• Additional sources of external exposure were associated with radiography operations. Using 

source strength and distance, radiographers would determine the exposure time necessary to 

expose film to produce a valid x-ray. NIOSH, using similar techniques, can estimate the dose 

to the radiographer and others that may be in the vicinity. This technique provides reasonable 

approaches to conservatively bound external doses.

• External dose during the residual contamination period at GSI is limited to the radiation 

emitted from residual uranium contamination (OCAS-IG-003). With no mechanical 

manipulation of the uranium (i.e., cutting, grinding, or machining) and no high-temperature 

applications, contamination can be estimated using data from other sites that worked with 

uranium metal. 

• Although no specific information regarding occupational medical dose has been identified for 

GSI, the dose associated with medical x-ray exams, if required as a condition of employment, 

can be bounded by using the assumptions in the complex-wide Technical Information 

Bulletin, Dose Reconstruction from Occupationally Related Diagnostic X-Ray Procedures 

(ORAUT-OTIB-0006). NIOSH believes this methodology supports its ability to bound the 

occupational medical x-ray doses for GSI.

• In sum, NIOSH determined that it has access to sufficient site-specific information to either 

(1) estimate the maximum internal and external radiation dose for every type of cancer for 

which radiation doses are reconstructed that could have been incurred under plausible 

circumstances by any member of the evaluated class; or (2) estimate the internal and external 

radiation doses to members of the evaluated class more precisely than a maximum dose 

estimate. 
HHS Special Exposure Cohort Determination:

General Steel Industries, Granite City, Illinois

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• The Board concurred with NIOSH’s determination.

Health Endangerment

Because the Secretary established that it is feasible to estimate with sufficient accuracy the radiation 

doses encountered by GSI, Granite City, Illinois, employees as specified in this class, a determination 

of health endangerment is not required.

V. Effect of the Determination

Members of the class of employees covered by this determination and their survivors continue to be 

eligible to submit claims for compensation under EEOICPA. As required for cancer claims covering 

other DOE and Atomic Weapons Employer employees (or Atomic Weapons Employees) not included 

in the SEC, qualified cancer claims under Part B of EEOICPA for members of this class will be 

adjudicated by the Department of Labor, in part, on the basis of radiation dose reconstructions, which 

will be conducted by NIOSH.

VI. Administrative Review of Determination

The determination provided in this report may be subject to an administrative review within HHS, 

pursuant to 42 C.F.R. § 83.18(a). On the basis of such a review, if the Secretary decides to designate 

the class of employees covered by this determination, in part or in whole, as an addition to the SEC, 

the Secretary would transmit a new report to Congress providing the designation and the criteria and 

findings on which the decision was based.